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One Simple Step to Help Offset the Expense of LL97

Although the future is uncertain, one thing we know for sure about 2024 is that compliance with New York City’s Local Law 97 (LL97) will make it more expensive to operate most commercial and residential buildings over 25,000 square feet.

The law, aimed at sharply boosting energy efficiency and reducing carbon emissions, was passed in April 2019 as part of the mayor’s Green New Deal. LL97 requires most buildings over 25,000 square feet to meet energy and GHG (greenhouse gas) emissions targets by 2024, with even stricter limits coming into force in 2030. Given the stringent financial penalties against aggressive reductions targets and the annual reports that need to be filed from May 2025 onward, compliance is going to be challenging.

In many cases, meeting requirements will likely entail expensive system upgrades or physical changes to buildings’ infrastructure and/or equipment. But there may be a very viable way for owners and property managers to significantly offset the new cost burden: using the wealth of available data to eliminate unnecessary energy consumption.

The process may seem daunting, but in most cases, it’s straightforward, because it relies on analysis of data from tools that are already in place, such as sensors, loggers, smart meters, utility bills and building automation systems.

Ripping and replacing before analyzing this data is like a doctor cutting into a patient before conducting a medical assessment. Here’s what I suggest owners do before taking drastic — and costly — action to comply with LL97:

Get the Data: Baseline and Benchmark
To understand where you’re going, you need to determine where you are today. You will need this information in a simple-to-use format so you can clearly understand how you are performing against buildings of similar size and function. Energy management systems equip you with cloud-based data in user-friendly formats that create the transpar- ency you need to succeed. You must aggregate and drill into data so that it can be audited. For example, you may want to separate out by tenant, area or system. Doing so will also enable you to determine where best to spend money to drive towards these targets.

To avoid costly implementations, any energy management system must integrate with whatever data is available in the building already (building automation systems, meters, loggers, etc.). The additional benefit of doing this is that your data will then be available in a single, centralized platform and much easier to manage.

To start your baseline, you must determine your building’s current GHG emissions and from there, determine the requirements you need to meet. Once you understand the numbers, you can create a plan that drives toward the compliance requirement over time.

Understand Traffic and Consumption
It’s important to know how levels of pedestrian traffic (residents, office tenants, staff, shoppers or visitors, depending on the building type) within a space drive the requirements of energy consumption (and therefore GHG emissions) and adjust accordingly. Is the energy consumption of your building aligned with the amount of pedestrian traffic that comes through it? Take a close look at available data, including interval data or even energy bills — what you find might surprise you.

For example, one of our clients uncovered a discrepancy between pedestrian trac and energy consumption, which in turn led to the discovery that the company had been running escalators connecting four floors after business hours — for five years! Or consider the case of a multifamily building that was incurring surprisingly high bills for water use even though occupancy levels and pedestrian traffic were normal. Upon investigation, management found that a resident was illegally operating a car wash out of the back of the building. Perhaps an extreme example, but it goes to demonstrate that you can’t manage what you can’t measure. Visibility is critical.

Match Operations to the Hybrid Working World
Much has been written about companies adjusting their office footprints in response to hybrid work, but much less is written about adjusting the operation of systems, which can also yield savings. In this post-COVID-19 world of remote/hybrid working, buildings are not occupied as they once were. However, we may not have adjusted the way the building is operated to sync with these behavior changes. For example, many office buildings attract fewer workers on Fridays, which means that lighting and cooling/heating can be reduced on those days.

The sensors or WiFi-based sys- tems that many companies use to track the number of users in an office provide the information needed to make adjustments. My colleagues in the U.K. used our own sensor-based data to compare the levels of pedestrian traffic in our London office with our energy use. When we discovered that our energy use was high on the weekends when traffic was low, we adjusted our heating and lighting systems accordingly.

Owners and managers of office buildings should follow our lead. They can also join forces with their tenants on such initiatives. Installing sensors and zoning energy in a building (on certain days) offers opportunity for fast reductions in energy usage.

Measure Real-time Consumption by Utility
The biggest challenge we see from clients is reliability of data. Data can be missing, contain spikes or other such anomalies, and unless anomalous data can be caught, reliability will always be an issue. A solid energy management system should provide you with alarms or a data-verification solution to track and inform you of “bad data” as it happens.

If issues in data are down to usage rather than errors, then finding out that you had a problem days after it happened (when it’s too late to do anything about it) is also suboptimal. Look for a system that provides automatic methods to catch not only bad or missing data, but “unusual events” in data that may indicate unexpected building performance or unauthorized adjustments in energy usage, thermo- stats or other building systems.

Measurement of real-time consumption shows you which systems are already providing high levels of energy efficiency. In other words, you know which parts of your utility infrastructure do not require retrofits. Most owners, I imagine, would be happy with that status quo. Any alternatives to “rip and replace” will undoubtedly be most welcome.

Tracking and Compiling Data
How do you start? Assess options for an energy management system and, where relevant, engage with a pedestrian-tracking solution. If possible, combine the data and obtain a baseline.

You can then set targets and understand more clearly if you are on track to meet your compliance requirements and avoid penalties.

Find a system that incorporates artificial intelligence (AI) into an- alytics, so that you can normalize data, manage GHG conversions and access auditable data, which will be a requirement.

And finally, don’t go it alone. There are plenty of resources and consultancy companies offering to guide you through the process, as well as valuable resources online, including government websites, to help you get started.

Potential Savings
Energy savings from tracking data and implementing simple fixes can be significant — and in fact as much as 30% of all energy used in buildings is wasted. What’s more, that percentage can convert to millions of dollars and thousands of tons of CO2 emissions, exactly the kind of outcomes that align with the goals of LL97.

So, make sure to take the important step of data analysis before you embark on a costly rip-and-replace program. You may just find that compliance and financial savings are not mutually exclusive.